The assessee was a non-resident. He returned to India and filed his Income-tax return for the assessment year 2016-17. In the meanwhile, Parliament introduced the Black Money (Undisclosed Foreign Income and Assets) and Imposition of tax Act, 2015. The assessee was under the bona fide belief that disclosure under Schedule FA was to be made only from the assessment year 2017-18. Subsequently he was advised that even for the assessment year 2016-17, details of foreign assets owned had to be included in Schedule FA. Accordingly, the assessee filed a revised return on August 30, 2018, but since the period prescribed for filing the revised return under section 139(5) of the Income-tax Act, 1961 had expired, the return was filed physically. He received a notice of penalty under the 2015 Act for failure to furnish the return of income and information. Penalty was imposed overruling his objections. On a writ petition to quash the order dismissing the petition the Court held that this Court under Article 226 of the Constitution of India cannot exercise the role of an appellate authority defined under the Black Money Act to deal with the controversy if brought into motion. Petitioner is well within the right to assail the aforementioned order, as the impugned order is dated 17.3. 2020 and the limitation in the instant case expired during the lock down but as per the Government directive and judgment of the Full Bench of this Court limitation prescribed already stood extended. Petitioner if so advised shall be at liberty to assail the aforementioned order. Any observation hereinabove would not prejudice the right of the petitioner in case the remedy is availed.(AY.2016-17)